TRANSFER PRICES: MECHANISMS, METHODS AND INTERNATIONAL APPROACHES

Transfer prices are considered the prices paid for the goods or services in a cross-border transaction between affiliates companies, often significant reduced or increased in order to avoid the higher imposing rates from one jurisdiction. Presently, over 60% of cross-border transfers are represented by intra-group transfers. The paper presents the variety of methods and mechanisms used by the companies to transfer the funds from one tax jurisdiction to another in order to avoid over taxation.transfer pricing, intra-firm transaction, tax jurisdiction

THE FREEDOM OF GOD AND THE FREEDOM OF MAN IN FATHER DUMITRU STĂNILOAE"™S THEOLOGY

God is the supreme Mystery of existence, He is by His own power above existence. God is the tripersonal super-essence of spiritual nature, above all spirituality that we may understand or imagine. He is the one Who brings everything into existence and that is why there is a fundamental difference between God and creation; the origin and the existence of the creation depend on the will and the creative work of God. As personal super-essence and super- existence, God is completely free because He cannot be closed into a reference system; He is the ultimate instance of all His decisions and acts. Man, created in the image of God reflects at the level of creation the freedom of God. As created existence, he is part of a reference system of the created world, which depends on God in its existence and becoming. As personal existence, in the image of God, the human person is capable of an existence that is not entirely enclosed into the reference system of the created nature; he is called to the free communion with God and it is the ultimate instance that decides his thoughts, acts and words. Man guards and increases his freedom or loses it according to the manner in which he professes it. For within the freedom of man the possibility to state the freedom is involved, at the same time renouncing it. The paradox of the freedom of man consists of the fact that man gives up his freedom through his own freedom because of pride or because he leaves the communion with God, Who offers him the true freedom

An overview of current status of carbon dioxide capture and storage technologies

AbstractGlobal warming and climate change concerns have triggered global efforts to reduce the concentration of atmospheric carbon dioxide (CO2). Carbon dioxide capture and storage (CCS) is considered a crucial strategy for meeting CO2 emission reduction targets. In this paper, various aspects of CCS are reviewed and discussed including the state of the art technologies for CO2 capture, separation, transport, storage, leakage, monitoring, and life cycle analysis. The selection of specific CO2 capture technology heavily depends on the type of CO2 generating plant and fuel used. Among those CO2 separation processes, absorption is the most mature and commonly adopted due to its higher efficiency and lower cost. Pipeline is considered to be the most viable solution for large volume of CO2 transport. Among those geological formations for CO2 storage, enhanced oil recovery is mature and has been practiced for many years but its economical viability for anthropogenic sources needs to be demonstrated. There are growing interests in CO2 storage in saline aquifers due to their enormous potential storage capacity and several projects are in the pipeline for demonstration of its viability. There are multiple hurdles to CCS deployment including the absence of a clear business case for CCS investment and the absence of robust economic incentives to support the additional high capital and operating costs of the whole CCS process

Influence of generalized focusing of few-cycle Gaussian pulses in attosecond pulse generation

In contrast to the case of quasi-monochromatic waves, a focused optical pulse in the few-cycle limit may exhibit two independent curved wavefronts, associated with phase and group retardations, respectively. Focusing optical elements will generally affect these two wavefronts differently, thus leading to very different behavior of the pulse near focus. As limiting cases, we consider an ideal diffractive lens introducing only phase retardations and a perfect non-dispersive refractive lens (or a curved mirror) introducing equal phase and group retardations. We study the resulting diffraction effects on the pulse, finding both strong deformations of the pulse shape and shifts in the spectrum. We then show how important these effects can be in highly nonlinear optics, by studying their role in attosecond pulse generation. In particular, the focusing effects are found to affect substantially the generation of isolated attosecond pulses in gases from few-cycle fundamental optical fields.Comment: 8 pages and 6 figure

Relación entre práctica deportiva y rendimiento académico en alumnos de Educación Primaria

En este trabajo se lleva a cabo una revisión bibliográfica de los principales estudios que tratan la relación entre la práctica deportiva y el rendimiento académico. El logro de un rendimiento académico óptimo en la escuela es el principal objetivo de la enseñanza actual. Por otra parte, el nivel de sedentarismo en la población ha aumentado considerablemente en los últimos años, llegando a ser considerado un problema mundial. Para solventarlo, los expertos sugieren la práctica de actividad física y deportiva diaria debido a las mejoras fisiológicas que genera en el organismo, y añaden también su utilidad para incrementar el rendimiento académico debido a los beneficios neurológicos, cognitivos, psicológicos y sociales que produce, concluyendo que los alumnos que realizan mayor práctica deportiva obtienen también un mayor rendimiento académico. Por último, se realiza un análisis crítico de la bibliografía consultada teniendo en cuenta posibles limitaciones de los estudios mencionados.Grado en Educación Primari

Ioan Halmaghi and the “wondrous craft” of the Păscălie. Bibliomancy and the calculation systems of eastern chronology at the end of the eighteenth century

Along with 19th-century folklore material, church documents from the 18th and 19th centuries emphasize the Păscălia as a book used in bibliomancy. In this study, I aim to explore the originally allowed and designated functions of this writing, and to provide an explanation for why this book was associated with the world of bibliomancy in both folklore and in the officially sanctioned culture of the Uniate clergy from Transylvania. Furthermore, by focusing on the specific case of the Uniate vicar Ioan Halmaghi, who was educated in Roman-Catholic institutions, I set out to explore the attitude of the elite clergy toward this text, and to highlight how a corpus of pre-modern and un-Western knowledge was simply ejected into the sphere of magic and superstition

A Study of the Temperature Correction Methods for Reciprocating Engine Flight Testing under non Standard Conditions

Federal Aviation Regulations require aircraft reciprocating engines to comply with temperature limits under pre-defined hot-day conditions. When the test is conducted on other than those conditions, the Regulations provide equations to convert the temperature registered into values considered to be corresponding to a hot-day scenario. It is known by the flight test community that those equations over compensate for flying in non-hot day conditions. As a consequence of that, an aircraft that could be certified under hot day conditions may not be certifiable in a colder atmosphere. This thesis confirmed that the Piper Saratoga complies with the regulations on cooling for cylinder head temperatures, and provides a better rationale to correct for other than hot-day conditions

Thermal Cooling Effects in the Microstructure and Properties of Cast Cobalt-Base Biomedical Alloys

Joint replacement prosthesis is widely used in the biomedical field to provide a solution for dysfunctional human body joints. The demand for orthopedic knee and hip implants motivate scientists and manufacturers to develop novel materials or to increase the life of service and efficiency of current materials. Cobalt-base alloys have been investigated by various researchers for biomedical implantations. When these alloys contain Chromium, Molybdenum, and Carbon, they exhibit good tribological and mechanical properties, as well as excellent biocompatibility and corrosion resistance. In this study, the microstructure of cast Co-Cr-Mo-C alloy is purposely modified by inducing rapid solidification through fusion welding processes and solution annealing heat treatment (quenched in water at room temperature. In particular the effect of high cooling rates on the athermal phase transformation FCC(Ɣ)↔HCP(ε) on the alloy hardness and corrosion resistance is investigated. The Co-alloy microstructures were characterized using metallography and microscopy techniques. It was found that the as cast sample typically dendritic with dendritic grain sizes of approximately 150 µm and containing Cr-rich coarse carbide precipitates along the interdendritic boundaries. Solution annealing gives rise to a refined microstructure with grain size of 30 µm, common among Co-Cr-Mo alloys after heat treating. Alternatively, an ultrafine grain structure (between 2 and 10 µm) was developed in the fusion zone for specimens melted using Laser and TIG welding methods. When laser surface modification treatments were implemented, the developed solidification microstructure shifted from dendritic to a fine cellular morphology, with possible nanoscale carbide precipitates along the cellular boundaries. In turn, the solidified regions exhibited high hardness values (461.5HV), which exceeds by almost 110 points from the alloy in the as-cast condition. The amount of developed athermal ɛ -martensite phase was determined using X-ray diffractrometry. It was found that the amount of ɛ -martensite increases significantly from 2% for the Laser surface processing to 13% in the as cast specimen, 24% in the annealed specimen, and 51% for the TIG surface processing. Moreover, the corrosion rate in Ringer solution was calculated by applying the Tafel extrapolation method on each alloy condition. The lowest corrosion rate (0.435 µm/year) was achieved in the Laser treated alloy and it is attributed to the lack of appreciable athermal ɛ -martensite. The highest corrosion rate (15.5 µm/year) was found to occur in the TIG treated alloy, which possesses the largest amount of ɛ -martensite. In turn, this suggests that surface modification through melting induces variable amounts of athermal ɛ -martensite in the as-cast Co-Cr-Mo-C alloys. Apparently, rapid solidification of melted surfaces in the Co-alloy is highly effective in modifying the induced amounts of HCP phase, and hence, the exhibited properties